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entitled 'Distance Education: Improved Data on Program Costs and
Guidelines on Quality Assessments Needed to Inform Federal Policy'
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Report to Congressional Requesters:
United States General Accounting Office:
GAO:
February 2004:
Distance Education:
Improved Data on Program Costs and Guidelines on Quality Assessments
Needed to Inform Federal Policy:
GAO-04-279:
GAO Highlights:
Highlights of GAO-04-279, a report to congressional requesters
Why GAO Did This Study:
Distance education—that is, offering courses by Internet, video, or
other forms outside the classroom—has changed considerably in recent
years and is a growing force in postsecondary education. More than a
decade ago, concerns about fraud and abuse by some correspondence
schools led to federal restrictions on, among other things, the
percentage of courses a school could provide by distance education and
still qualify for federal student aid. Given the recent changes in
distance education, GAO was asked to review the extent to which the
restrictions affect schools’ ability to offer federal student aid and
the Department of Education’s assessment of the continued
appropriateness of the restrictions.
Additionally, GAO was asked to look at the extent to which accrediting
agencies evaluate distance education programs, including their
approach for assessing student outcomes.
What GAO Found:
While federal restrictions on the size of distance education programs
affect only a small number of schools’ ability to offer federal
student aid, the growing popularity of distance education could cause
the number to increase in the future. GAO found that 14 schools were
either now adversely affected by the restrictions or would be affected
in the future; collectively, these schools serve nearly 225,000
students. Eight of these schools, however, will remain eligible to
offer federal student aid because they have been granted waivers from
the restrictions by Education. Education granted the waivers as part
of a program aimed at assessing the continued appropriateness of the
restrictions given the changing face of distance education. In
considering the appropriateness of the restrictions, there are several
policy options for amending the restrictions; however, amending the
restrictions to improve access would likely increase the cost of the
federal student aid programs. One way to further understand the effect
of amending the restrictions would be to study data on the cost of
granting the waivers to schools, but Education has yet to develop this
information.
The seven accrediting agencies GAO reviewed varied in the extent to
which they included distance education programs in their reviews of
postsecondary institutions. All seven agencies had developed policies
for reviewing these programs; however, there were differences in how
and when they reviewed the programs. Agencies also differed in the
extent to which they included an assessment of student outcomes in
their reviews. GAO’s work in examining how organizations successfully
focus on outcomes shows that they do so by (1) setting measurable
goals for program outcomes, (2) developing strategies for meeting
these goals, and (3) disclosing the results of their efforts to the
public. Measured against this approach, only one of the seven
accrediting agencies we reviewed had policies that require schools to
satisfy all three components. As the key federal link to the
accreditation community, Education could play a pivotal role in
encouraging an outcomes-based model.
What GAO Recommends:
GAO recommends that Education provide data on the cost of waiving
restrictions on distance education and develop guidelines with
accrediting agencies and schools on assessing distance education
quality.
In commenting on a draft of this report, Education generally agreed
with our findings and the merits of our recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-04-279.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Cornelia M. Ashby at
(202) 512-8403 or ashbyc@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Current Federal Restrictions on Distance Education Affect Few Schools'
Ability to Offer Federal Student Aid, but Numbers Could Increase in the
Future:
According to Education, the Demonstration Program Has Not Revealed
Negative Consequences of Waiving the Current Federal Restrictions on
Distance Education:
Accrediting Agency Reviews of Distance Education Varies:
Accrediting Agency Assessment of Student Learning Outcomes in Their
Reviews Varies Considerably:
Conclusions:
Recommendations:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Education:
Appendix III: GAO Contacts and Staff Acknowledgments:
Contacts:
Staff Acknowledgments:
Tables:
Table 1: Examples of Potential Differences in Electronically
Transmitted Distance Education and Traditional Classroom Instruction:
Table 2: Schools That Current Restrictions on Distance Education
Programs Affect or Nearly Affect:
Table 3: Evaluation of Policy Options Related to Amending the 50-
Percent Rules:
United States General Accounting Office:
Washington, DC 20548:
February 26, 2004:
The Honorable Edward M. Kennedy:
Ranking Minority Member:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
The Honorable George Miller:
Ranking Minority Member:
Committee on Education and the Workforce:
House of Representatives:
The Honorable Rubén Hinojosa:
The Honorable Major Owens:
House of Representatives:
As the largest provider of student financial aid to postsecondary
students, the federal government has a substantial interest in the
quality of courses and programs offered by postsecondary schools. In
fiscal year 2003, students at more than 6,000 postsecondary schools
received about $60 billion in loans and grants through federal student
aid programs. Distance education--that is, taking courses by computer,
by television, or by correspondence[Footnote 1]--is an increasing part
of the educational landscape in which students pursue a degree or
certificate. During the 1999-2000 school year, for example, an
estimated 1.5 million students, or about 1 of every 13 postsecondary
students, took at least one telecommunications[Footnote 2] distance
education course.[Footnote 3]
Recent changes in distance education call into question the continued
relevance of federal policies designed to limit the extent to which
schools can deliver distance education courses and still qualify to
participate in the federal student aid programs. A school is not
eligible to participate in the federal student aid programs if the
school (1) offers more than half of its courses through correspondence,
(2) has half or more of its students enrolled in correspondence
courses, or (3) offers correspondence and telecommunication courses
that amount to half or more of all courses. Collectively, these
restrictions are known as the "50-percent rules."[Footnote 4] More than
a decade ago concerns about widespread fraud and abuse at some
correspondence schools led the Congress to enact these limiting
policies in order to protect the federal student aid programs. The
rapid growth of distance education at mainstream schools, primarily
through newer delivery modes such as Internet-based classes, have led
to questions about whether these restrictions are still the most
appropriate way to guard against fraud and abuse. In 1998, the Congress
authorized the Department of Education (Education) to administer a
Distance Education Demonstration Program (Demonstration Program) to,
among other things, evaluate these restrictions.[Footnote 5]
A change in federal policy to reduce the restrictions might result in
an increased reliance on the work of accrediting agencies[Footnote 6]
to ensure program quality and guard against fraud and abuse. These
agencies already review schools' programs, including distance
education, for quality assurance purposes. To be eligible for the
federal student aid programs, a school must be periodically reviewed
and accredited by an agency recognized by Education. In doing so,
Education, is responsible for determining that agencies have certain
standards and procedures in place for evaluating educational quality.
While the accreditation process applies to both distance education and
campus-based instruction, many accreditation practices focus on campus-
based education, such as the adequacy of classroom facilities or
instructional time spent with students. These measures can be more
difficult to apply to distance education, when students are not on
campus or may not interact with faculty in person. In this new
environment, postsecondary education officials are increasingly
recommending that student-learning outcomes--such as course completion
rates or success in problem solving and written communication--be
incorporated into assessments of distance education programs and
campus-based programs.
In this context, and in light of the upcoming reauthorization of the
Higher Education Act of 1965, as amended (Higher Education Act), you
asked us to review various issues with respect to distance education.
For this report, we reviewed both quality control approaches for
distance education--federal restrictions on the size of distance
education programs and accreditation reviews of distance education
courses. Separately from this effort, we reported to you on issues
related to the demographic characteristics of distance education
students and the use of distance education by Minority Serving
Institutions.[Footnote 7] For this report, as agreed with your offices,
we focused our work on the following four questions:
* To what extent do current federal restrictions on distance education
affect schools' ability to offer federal student aid to their students?
* What has Education's Demonstration Program revealed with respect to
the continued appropriateness of these restrictions?
* To what extent do accreditation agencies include distance education
in their reviews of schools or programs?
* As they evaluate distance education and campus-based programs, to
what extent do accreditation agencies assess student-learning outcomes?
To address the two questions about current statutory and regulatory
restrictions on federal aid, we obtained information from Education and
other experts on how many of the over 6,000 postsecondary institutions
had been affected by these provisions or might be affected in the
future--that is, schools that might reach the limitations on the size
of their distance education programs if their growth in this area
continues. We interviewed officials at each of the institutions whose
eligibility for the student aid programs had been affected or could be
affected by the restrictions to determine the extent to which their
ability to offer federal student aid to their students had been
impacted.[Footnote 8] We also interviewed officials at Education who
are responsible for assessing distance education issues and reviewed
monitoring reports on participating institutions involved in the
Demonstration Program and annual reports to the Congress.[Footnote 9]
To address questions related to the work of accrediting agencies, we
focused on the policies of seven accrediting agencies that collectively
are responsible for more than two-thirds of all distance education
programs.[Footnote 10] We evaluated the extent that the agencies assess
student learning outcomes using criteria that we had developed in a
variety of past work addressing performance and accountability
issues.[Footnote 11] We conducted our work between October 2002 and
February 2004 in accordance with generally accepted government auditing
standards. See appendix I for further explanation of our approach and
methodology.
Results in Brief:
While federal restrictions on the size of distance education programs
affect only a small number of schools' ability to offer federal student
aid, the growing popularity of distance education could cause the
number to increase in the future. We found that 14 schools were either
now adversely affected by the restrictions or would be affected in the
future; collectively, these schools serve nearly 225,000 students.
Eight of the 14 schools are currently exempt from restrictions on the
size of their distance education programs because they are
participating in the Demonstration Program. Three of the remaining 5
schools in the Demonstration Program are negotiating with Education to
obtain a waiver. One school that is not in the Demonstration Program
anticipates becoming ineligible because of the restrictions in the
future.
According to Education, the Demonstration Program revealed no evidence
that waiving the current restrictions results in negative consequences,
and in its most recent report on the program, Education said that there
is a need to amend the laws and regulations governing federal student
financial aid to expand distance education opportunities. However,
deciding whether to eliminate or modify these restrictions involves
consideration of several factors, including the extent to which any
changes would improve access to postsecondary schools, the impact that
changes would have on Education's ability to prevent institutions from
conducting fraudulent or abusive practices, and the cost of
implementation. Our analysis of these factors indicates that
eliminating the restrictions without ensuring some form of management
accountability would likely incur a higher risk for fraud and abuse
than currently exists. Other options that involve some form of
accountability include continuing to allow waivers (and monitoring
schools that receive the waivers) or using other thresholds, such as
student loan default rates, to decide which schools could be exempted
from the restrictions. Education recognizes that there could be a cost
to the federal student aid programs of eliminating or modifying the
restrictions. Information from the Demonstration Program on potential
budgetary impacts could inform policymakers; however, Education has yet
to describe such information in its reports.
Accrediting agencies we reviewed varied in the extent to which their
reviews include distance education. All seven agencies had developed
standards, policies, and guidelines for reviewing distance education
programs; however, there were differences in the extent to which their
approaches ensured that distance education was included in assessing
the quality of a school's educational program. The Higher Education Act
gives agencies considerable flexibility in developing these standards,
policies, and guidelines, and the agencies differed considerably in
when and how they included reviews of distance education. For example,
one agency includes distance education programs in its review when 25
percent or more of a program's courses are offered by distance
education; three other agencies do not review distance education
programs until the percentage of courses rises to 50 percent; and the
remaining three agencies apply various other thresholds in considering
when to review distance education programs.
The accrediting agencies we reviewed also differed in the extent to
which they included an assessment of student learning outcomes--for
either classroom-based or distance learning--in their accreditation
reviews. Several agencies have recently placed greater emphasis on
holding institutions accountable for student learning outcomes--a
strategy recommended by such organizations as the Council for Higher
Education Accreditation, a national organization representing
accrediting agencies, and by other postsecondary education officials.
Our work in examining how organizations of various types successfully
focus on outcomes shows that they do so by (1) setting measurable goals
for program outcomes, (2) developing strategies for meeting these
goals, and (3) disclosing the results of their efforts to the public.
Measured against this approach, only one of the seven accrediting
agencies we reviewed has policies and procedures that require schools
to satisfy all three components. At present, there is no federal
requirement that accrediting agencies require institutions to use such
an approach, and while Education has expressed interest in holding
postsecondary institutions accountable for student learning outcomes,
it does not have the statutory authority to impose such requirements
via the accrediting agencies. However, as the central federal link to
the accreditation community, Education could take a more proactive role
in promoting accountability.
In this report, we are making recommendations to the Secretary of
Education to include empirical data in future Demonstration Program
reports on the cost to the federal student aid programs of waiving the
50-percent rules. With respect to accreditation, we are recommending
that the Secretary of Education (1) develop, with the help of
accrediting agencies and schools, guidelines or a mutual understanding
for more consistent and thorough assessment and public disclosure of
campus-based and distance education outcomes, including components of a
system for holding institutions accountable for such outcomes and (2)
if necessary, request authority from the Congress to require that
accrediting agencies use these guidelines in their accreditation
efforts.
In commenting on a draft of this report, Education generally agreed
with our findings and the merits of our recommendations. For instance,
Education said that it will consider the potential cost of the federal
student aid programs of eliminating the 50-percent rules; however, due
to the timing of the process of reauthorizing the Higher Education Act,
Education believes it is unlikely these estimates will become part of a
future report to Congress on the Demonstration Program.
Background:
Distance education is a growing force in postsecondary education, and
its rise has implications for the federal student aid programs. Studies
by Education indicate that enrollments in distance education quadrupled
between 1995 and 2001. By the 2000-2001 school year, nearly 90 percent
of public 4-year institutions were offering distance education courses,
according to Education's figures. Entire degree programs are now
available through distance education, so that a student can complete a
degree without ever setting foot on campus. Students who rely
extensively on distance education, like their counterparts in
traditional campus-based settings, often receive federal aid under
Title IV of the Higher Education Act, as amended, to cover the costs of
their education, though their reliance on federal aid is somewhat less
than students who are not involved in any distance education. We
previously reported that 31 percent of students who took their entire
program through distance education received federal aid, compared with
39 percent of students who did not take any distance education
courses.[Footnote 12]
There is growing recognition among postsecondary officials that changes
brought about by the growing use of distance education need to be
reflected in the process for monitoring the quality of schools'
educational programs. Although newer forms of distance education--such
as videoconferencing or Internet courses--may incorporate more elements
of traditional classroom education than older approaches like
correspondence courses, they can still differ from a traditional
educational experience in many ways. Table 1 shows some of the
potential differences.
Table 1: Examples of Potential Differences in Electronically
Transmitted Distance Education and Traditional Classroom Instruction:
Electronically transmitted distance education setting: Courses may
involve electronic content only (e.g., course modules on a compact
disk or a school's Web server);
Traditional classroom setting: Courses generally involve lectures or
discussions with actual instructors.
Electronically transmitted distance education setting: When the
instruction involves presentations by instructors, students often may
have only indirect contact with them (e.g., over a video network or
through e-mail);
Traditional classroom setting: Students generally have face-to-face
contact with instructors.
Electronically transmitted distance education setting: School may have
no campus, may be hundreds of miles away, and research, tutoring, or
counseling resources may be offered online rather than in-person;
Traditional classroom setting: School has research facilities,
tutoring, and other resources directly available on a campus.
Electronically transmitted distance education setting: Provider of the
distance education coursework may be other than the school in which
the student is enrolled;
Traditional classroom setting: School in which the student is enrolled
generally has direct responsibility for course content.
Source: GAO analysis of reports and issue papers on distance education.
[End of table]
The Higher Education Act focuses on accreditation--a task undertaken by
outside agencies--as the main tool for ensuring quality in
postsecondary programs. Under the act, accreditation for purposes of
meeting federal requirements can only be done by agencies that are
specifically "recognized" by Education. In all, Education recognizes 62
accrediting agencies.[Footnote 13] Some, such as Middle States
Association of Colleges and Schools - Commission on Higher Education
and the Western Association of Schools and Colleges - Accrediting
Commission for Community and Junior Colleges, accredit entire
institutions that fall under their geographic or other purview. Others,
such as the American Bar Association--Council of the Section of Legal
Education and Admissions to the Bar, accredit specific programs or
departments. Collectively, accrediting agencies cover public and
private 2-year and 4-year colleges and universities as well as for-
profit vocational schools and nondegree training programs. Thirty-nine
agencies are recognized for the purpose of accrediting schools or
programs for participation in the federal student aid programs.
Education is required to recognize or re-recognize these agencies every
5 years.
In order to be recognized by Education as a reliable authority with
regard to educational quality, accrediting agencies must, in addition
to meeting certain basic criteria, establish standards that address 10
broad areas of institutional quality, including student support
services, facilities and equipment, and success with respect to student
achievement.[Footnote 14] While the statute provides that these
standards must be consistently applied to an institution's courses and
programs of study, including distance education courses and
programs,[Footnote 15] it also gives accrediting agencies flexibility
in deciding what to require under each of the 10 areas, including
flexibility in whether and how to include distance education within the
accreditation review. The current accreditation process is being
carried out against a public backdrop of concern about holding schools
accountable for student learning outcomes. For example, concerns have
been expressed about such issues as the following:
* Program completion--the percentage of full-time students who graduate
with a 4-year postsecondary degree within 6 years of initial enrollment
was about 52 percent in 2000.[Footnote 16]
* Unprepared workforce--business leaders and educators have pointed to
a skills gap between many students' problem solving, communications,
and analytical thinking ability and what the workplace
requires.[Footnote 17]
To address concerns such as these, there is increased interest in using
outcomes more extensively as a means of ensuring quality in distance
education and campus-based education. The Council for Higher Education
Accreditation--a national association representing accreditors--has
issued guidelines on distance education and campus-based programs,
that, among other things, call for greater attention to student
learning outcomes.[Footnote 18] Additionally, in May 2003,[Footnote 19]
we reported that 18 states are promoting accountability by publishing
the performance measures of their colleges and universities, including
retention and graduation rates, because some officials believe that
this motivates colleges to improve their performance in that area. At
the national level, Education stated in its 2004 annual plan that it
will propose to hold institutions more accountable for results, such as
ensuring a higher percentage of students complete their programs on-
time. The congressionally appointed Web-based Education
Commission[Footnote 20] has also called for greater attention on
student outcomes. The Commission said that a primary concern related to
program accreditation is that "quality assurance has too often measured
educational inputs (e.g., number of books in the library, etc.) rather
than student outcomes."[Footnote 21] Finally, the Business Higher
Education Forum--an organization representing business executives and
leaders in postsecondary education--has said that improvements are
needed in adapting objectives to specific outcomes and certifiable job-
skills that address a shortage of workers equipped with analytical
thinking and communication skills.
Current Federal Restrictions on Distance Education Affect Few Schools'
Ability to Offer Federal Student Aid, but Numbers Could Increase in the
Future:
Although current federal restrictions on the extent to which schools
can offer programs by distance education and still qualify to
participate in federal student aid programs affect a small number of
schools, the growing popularity of distance education could cause the
number to increase in the future. We found that 14 schools were either
now adversely affected by the restrictions or would be affected in the
future; collectively, these schools serve nearly 225,000 students.
Eight of the 14 schools are exempt from the restrictions because they
have received waivers as participants in Education's Demonstration
Program, under which schools can remain eligible to participate in the
student aid programs even if the percentage of distance education
courses or the percentage of students involved in distance education
rises above the maximums set forth in the law.[Footnote 22] Three of
the remaining 5 schools in the Demonstration Program are negotiating
with Education to obtain a waiver.
The 14 schools that the current federal restrictions--called the 50-
percent rules--affect, or nearly affect, are shown in table 2. They
vary in a number of respects. For example, 2 are large (the University
of Phoenix has nearly 170,000 students and the University of Maryland
University College has nearly 30,000), while 5 have fewer than 1,000
students. Six of the 14 are private for-profit schools, 5 are private
nonprofit schools, and 3 are public. Thirteen of the schools are in
Education's Demonstration Program, and without the waivers provided
under this program, 8 of the 13 would be ineligible to participate in
federal student aid programs because 50 percent or more of their
students are involved in distance education. One school that is not
part of the Demonstration Program faces a potential problem in the near
future because of its growing distance education programs.[Footnote 23]
Table 2: Schools That Current Restrictions on Distance Education
Programs Affect or Nearly Affect:
Schools in Education's Demonstration Program that have substantial
distance education programs:
1. Name: Capella University[A];
Number of students in 2000-2001: 3,985;
Percent of students involved in distance education: 100;
Type of school: Private for profit;
When school first offered distance education: 1993;
2001 default rate: 0.50 %.
2. Name: Charter Oak State College[A];
Number of students in 2000-2001: 1,496;
Percent of students involved in distance education: 100;
Type of school: Public;
When school first offered distance education: 1992;
2001 default rate: n/a.
3. Name: Eastern Oregon University[A];
Number of students in 2000-2001: 4,908;
Percent of students involved in distance education: 69;
Type of school: Public;
When school first offered distance education: 1970;
2001 default rate: 5.6 %.
4. Name: Southern Christian University[A];
Number of students in 2000- 2001: 1,029;
Percent of students involved in distance education: 93;
Type of school: Private nonprofit;
When school first offered distance education: 1993;
2001 default rate: 1 %.
5. Name: U.S. Sports Academy[A];
Number of students in 2000-2001: 704;
Percent of students involved in distance education: 100;
Type of school: Private nonprofit;
When school first offered distance education: 2001;
2001 default rate: 0 %.
6. Name: University Maryland University College[A];
Number of students in 2000-2001: 29,442[B];
Percent of students involved in distance education: 77;
Type of school: Public;
When school first offered distance education: 1994;
2001 default rate: 4.5 %.
7. Name: Walden University[A];
Number of students in 2000-2001: 1,544;
Percent of students involved in distance education: 100;
Type of school: Private for profit;
When school first offered distance education: 1970;
2001 default rate: 2.8 %.
8. Name: Western Governor's University[A];
Number of students in 2000- 2001: 242;
Percent of students involved in distance education: 100;
Type of school: Private nonprofit;
When school first offered distance education: 1999;
2001 default rate: n/a.
9. Name: Jones International University[B];
Number of students in 2000- 2001: 446;
Percent of students involved in distance education: 100;
Type of school: Private for profit;
When school first offered distance education: 1995;
2001 default rate: n/a.
10. Name: North Central University[C];
Number of students in 2000-2001: 319;
Percent of students involved in distance education: 100;
Type of school: Private for profit;
When school first offered distance education: 1997;
2001 default rate: n/a.
11. Name: National Technical University[C];
Number of students in 2000- 2001: 969;
Percent of students involved in distance education: 100;
Type of school: Private nonprofit;
When school first offered distance education: 1984;
2001 default rate: n/a.
12. Name: University of Phoenix;
Number of students in 2000-2001: 169,021;
Percent of students involved in distance education: 29[D, E];
Type of school: Private for profit;
When school first offered distance education: 1989;
2001 default rate: 5.8 %.
13. Name: American Intercontinental University;
Number of students in 2000-2001: 5,885;
Percent of students involved in distance education: 54[E, F];
Type of school: Private for profit;
When school first offered distance education: 2001;
2001 default rate: 5.4 %.
Schools eligible for the federal student aid programs that may have
problems with the 50-percent rules in the future, but that are not in
the Demonstration Program:
14. Name: St. Joseph's College;
Number of students in 2000-2001: 5,063;
Percent of students involved in distance education: 56[G];
Type of school: Private nonprofit;
When school first offered distance education: 1974;
2001 default rate: 4.1 %.
Source: GAO interview with officials at the 14 schools and Education's
fiscal year 2001 student loan cohort default rate database.
N/A indicates the 2001 student loan cohort default rate database did
not have information on the school or the school did not have any
students with loans in repayment.
[A] Denotes a school that has received a waiver from the 50-percent
rules.
[B] University of Maryland University College also serves a large
number of military personnel stationed in Europe and Asia. These
students are not included in this figure.
[C] Denotes a school that has received a waiver from the 50-percent
rules pending Education's approval of the schools administrative and
financial systems for managing the federal student aid programs.
[D] In 2000-2001, the University of Phoenix had almost 49,000 students
involved in distance education, or about 29 percent of its entire
student body.
[E] According to an Education official, at least half of the programs
offered by the University of Phoenix and American Intercontinental
University are degree programs so that their students enrolled in
telecommunications courses are not considered to be enrolled in
correspondence courses, so long as the total amount of
telecommunication and correspondence courses is less than 50-percent of
all the courses at those institutions.
[F] In 2002-2003, American Intercontinental University had 7,000
students involved in distance education (out of 13,000 students) or
about 54 percent of its student body.
[G] St. Joseph's College has received a waiver from the 50 percent
rules from the Secretary of Education because the students enrolled in
its correspondence courses receive no more than 5 percent of all
federal student aid received by students at the institution--an
allowable exemption under federal regulations. However, a school
official indicated that the number of distance education students that
receive financial aid is growing and the school anticipates that it
could have a problem with the 50-percent rules in the future if the
student aid offered to distance education students exceeds 5 percent of
the total aid received by students.
[End of table]
Two examples from among the 14 schools will help illustrate the effect
that the restrictions on the size of distance education programs have
on schools and their students.
* The University Maryland University College, a public institution,
located in Adelphi, Maryland, had nearly 30,000 students and more than
70 percent of its students took at least one Internet course in the
2000-2001 school year. The college is participating in Education's
Demonstration Program and has received waivers to the restrictions on
federal student aid for schools with substantial distance education
programs. According to university officials, without the waivers, the
college and about 10,000 students (campus-based and distance education
students) would no longer receive about $65 million in federal student
aid.
* Jones International University, a private for-profit school founded
in 1993 and located in Englewood, Colorado, served about 450 students
in the 2000-2001 school year. The university offers all of its programs
online and offers no campus-based courses. The university has received
accreditation from the North Central Association of Colleges and
Schools, a regional accrediting agency that reviews institutions in 19
states. In August 2003, school administrators told us that they would
be interested in federal student program eligibility in the future. In
December 2003, the school became a participant in Education's
Demonstration Program and, therefore, its students will be eligible for
federal student aid when Education approves the school's administrative
and financial systems for managing the federal student aid programs.
According to Education, the Demonstration Program Has Not Revealed
Negative Consequences of Waiving the Current Federal Restrictions on
Distance Education:
In the second of two congressionally mandated reports on federal laws
and regulations that could impact access to distance education,
Education concluded, "[T]he Department has uncovered no evidence that
waiving the 50-percent rules, or any of the other rules for which
waivers were provided, has resulted in any problems or had negative
consequences." In its report, Education also stated that there is a
need to amend the laws and regulations governing federal student
financial aid to expand distance education opportunities, and officials
at Education recognize that several policy options are available for
doing so. A significant consideration in evaluating such options is the
cost to the federal student aid programs. Regarding these costs,
Education has not provided data on the cost of granting waivers to the
50-percent rules in the first two reports on the Demonstration Program.
Based in part on our discussions with Education officials and proposals
made by members of Congress,[Footnote 24] there appear to be three main
options for consideration in deciding whether to eliminate or modify
the current federal restrictions on distance education: (1) continuing
the use of case-by-case waivers, as in the current Demonstration
Program, coupled with regular monitoring and technical assistance; (2)
offering exceptions to those schools with effective controls already in
place to prevent fraud and abuse, as evidenced by such characteristics
as low default rates; or (3) eliminating the rules and imposing no
additional management controls. Evaluating these options involves three
main considerations: the extent to which the changes improve access to
postsecondary schools, the impact the changes would have on Education's
ability to prevent institutions from fraudulent or abusive practices,
and the cost to the federal student aid programs and to monitor schools
with substantial distance education programs. Our analysis of the three
options,[Footnote 25] as shown in table 3, suggests that while all
three would improve students' access to varying degrees, the first two
would likely carry a lower risk of fraud and abuse than the third,
which would eliminate the rules and controls altogether. We also found
support for some form of accountability at most of the 14 schools that
current restrictions affect or nearly affect. For example, officials at
11 of these schools said they were generally supportive of some form of
accountability to preserve the integrity of the federal student aid
programs rather than total elimination of the restrictions.
Table 3: Evaluation of Policy Options Related to Amending the 50-
Percent Rules:
Policy option: Continue the Demonstration Program, which allows for
waivers to the 50-percent rules and provides monitoring and technical
assistance on a routine basis;
Relative Impact on access to federal student aid for schools above the
current limits based on the 50- percent rules: Medium. Increased
access to federal student aid for postsecondary education would be
limited to students attending schools that have received waivers;
Risk of fraud and abuse: Low. As part of the Demonstration Program,
Education has provided oversight and technical assistance on a routine
basis. According to participants, this has resulted in improved
compliance with federal student aid program rules. Also, as part of
the application process, Education screens schools for the program;
this acts as another form of oversight;
Relative Impact to the federal student aid programs and cost to
monitor schools with substantial distance education programs: Medium.
Increased cost to the federal student aid programs would be limited to
those schools participating in the Demonstration Program. Education
would need to continue monitoring schools with staff located in its
field offices. Its ability to monitor substantially more schools on a
routine basis may be limited, however. For example, in 2001, Education
monitored less than 200 out of the over 6,000 schools eligible for the
federal student aid programs.
Policy option: Offering exceptions to the 50-percent rules to schools
with evidence of effective management controls, such as low default
rates. For example, a Senate proposal (S. 1445) offered schools a
waiver to the 50-percent rules if they had a default rate of 10
percent or less for each of the 3 most recent fiscal years;
Relative Impact on access to federal student aid for schools above the
current limits based on the 50-percent rules: Medium to high.
Increased access to federal student aid for postsecondary education
would be limited to students attending schools with low default
rates;
Risk of fraud and abuse: Low to medium. Our evaluation shows that all
9 schools eligible for the federal student aid programs (with loans in
repayment) and that have or may have problems with the 50-percent
rules had default rates of 6 percent or less in 2001. This alternative
ensures that default rates remain reasonable; however, technical
assistance and monitoring are not provided. One possible unintended
effect of this option is that if a school exceeds the designated
default rate, all students, including students enrolled in on-campus
programs, might become ineligible for the federal student aid
programs;
Relative Impact to the federal student aid programs and cost to
monitor schools with substantial distance education programs: Medium
to high. The federal student aid program would cost more under this
option since the only limiting factor would affect schools with high
default rates. Initially, monitoring default rates would take minimal
effort by Education, however, should rates increase, the costs
associated with managing and guaranteeing the defaulted loans would
increase.
Policy option: Eliminating the 50-percent rules with no additional
management controls;
Relative Impact on access to federal student aid for schools above the
current limits based on the 50-percent rules: High. Increased access
to federal student aid for students attending schools with substantial
distance education;
Risk of fraud and abuse: Medium to high. Without any monitoring or
technical assistance, this option offers the highest risk of
increasing fraud and abuse. Lessons learned from the Demonstration
Program suggest that eliminating the 50- percent rules without
adequate monitoring may increase the risk of fraud and abuse. For
example, Education identified problems at 15 of the 21 participants[A]
remaining in the program as part of its monitoring efforts.
Alternatively, relying on accrediting agencies to monitor compliance
with student aid rules may be difficult because accrediting agencies
do not consider it their role to act as "regulators" for the federal
government;
Relative Impact to the federal student aid programs and cost to
monitor schools with substantial distance education programs: High.
The federal student aid programs would incur greater costs since there
would be no limit on the number of distance education schools that
could participate. Initially, the cost to monitor could be low, but
such costs could increase substantially if fraud and abuse rise.
Source: GAO analysis.
[A] The most common problems that surfaced included weaknesses in
administrative systems for tracking satisfactory academic progress of
students and the enrollment status (i.e., whether students withdrew
from a class) of distance education students. Having sound
administrative systems for tracking these two areas are important
because they can result in an institution returning student aid funds
to the federal government if improperly administered.
[End of table]
The first option would involve reauthorizing the Demonstration Program
as a means of continuing to provide schools with waivers or other
relief from current restrictions. Even though exempting schools from
current restrictions on the size of distance education programs costs
the federal student aid programs, Education has yet to describe the
extent of the costs in its reports on the program. According to
Education staff, developing the data on the amount of federal student
aid could be done and there are no major barriers to doing so. The data
would prove valuable in determining the potential costs of various
policy options since the program is expanding in scope--five new
schools joined in December 2003--and additional reports will need to be
prepared for the Congress.
Our review of the Demonstration Program and our discussions with
Education officials surfaced two additional considerations that would
be worthwhile addressing if the Congress decided to reauthorize the
program. They relate to streamlining Demonstration Program requirements
and improving resource utilization.
* Reducing paperwork requirements. When the Congress authorized the
Demonstration Program, it required that Education evaluate various
aspects of distance education, including the numbers and types of
students participating in the program and the effective use of
different technologies for delivering distance education. These
requirements now may be redundant since Education collects such
information as part of its National Postsecondary Student Aid Study and
other special studies on distance education. Eliminating such
requirements could ease the paperwork burden on participating
institutions and Education staff.
* Limiting participation to schools that are adversely affected by
federal restrictions. Some schools participating in the Demonstration
Program do not need waivers to the 50-percent rules, because their
programs are not extensive enough to exceed current restrictions.
Limiting participation in the program to only schools that need relief
from restrictions on the size of distance education programs could ease
the administrative burden on Education. However, in the future, more
schools may be interested in receiving waivers if their distance
education programs expand.
Accrediting Agency Reviews of Distance Education Varies:
The seven accrediting agencies we reviewed varied in the extent to
which their institutional reviews included distance education. While
all seven agencies had adopted standards or policies calling for
campus-based and distance education programs to be evaluated using the
same standards, the agencies varied in (1) the extent to which agencies
required schools to demonstrate that distance education and campus-
based programs were comparable and (2) the size a distance education
program had to be before it was formally included in the overall
institutional review. While the Higher Education Act requires Education
to ensure that accrediting agencies have standards and policies in
place regarding the quality of education, including distance education,
it gives the agencies latitude with regard to the details of setting
their standards or policies. Differences in standards or policies do
not necessarily lead to differences in educational quality, but if one
accrediting agency's policies and procedures are more or less rigorous
than another's, the potential for quality differences may increase. An
Education official said the historical role of the federal government
in exerting control over postsecondary education has been limited.
Similarly, Education has limited authority to push for greater
consistency in areas related to the evaluation of distance education.
Accrediting Agency Actions for Evaluating Distance Education Programs:
The agencies we reviewed all had standards or policies in place for
evaluating distance education programs. The Higher Education Act does
not specify how accrediting agencies should review distance education
programs, but instead directs them to cover key subject areas, such as
student achievement, curricula, and faculty. The law does not specify
how accrediting agencies are to develop their standards or what an
appropriate standard should be. All seven agencies had a policy stating
that the standards they would apply in assessing a school's distance
education programs would be the same as the standards used for
assessing campus-based programs. The six regional accrediting agencies
within this group had also adopted a set of supplemental
guidelines[Footnote 26] to help schools assess their own distance
education programs.[Footnote 27]
While all the agencies had standards or policies in place for
evaluating distance education and campus-based learning, we found
variation among the agencies in the degree to which they required
institutions to compare their distance learning courses with their
campus-based courses. Five of the seven agencies, including the one
national accrediting agency reviewed, required schools to demonstrate
comparability between distance education programs and campus-based
programs. For example, one agency required each school to evaluate "the
educational effectiveness of its distance education programs (including
assessments of student learning outcomes, student retention, and
student satisfaction) to ensure comparability to campus-based
programs." Another accrediting agency required that the successful
completion of distance education courses and programs be similar to
those of campus-based courses and programs. The remaining two
accrediting agencies did not require schools to demonstrate
comparability in any tangible way.
A second area in which variations existed is in the threshold for
deciding when to conduct a review of a distance education program.
While accrediting agencies complete their major review of a school on a
multiyear cycle, federal regulations provide they also must approve
"substantive changes" to the accredited institutions' educational
mission or program. The regulations[Footnote 28] prescribe seven types
of change, such as a change in the established mission or objectives of
the institution, that an agency must include in its definition of a
substantive change for a school. For example, starting a new field of
study or beginning a distance education program might both be
considered a substantive change for a school. However, the seven
agencies vary in their definition of "substantive" so the amount of
change needed for such a review to occur varies from agency to agency.
Three of the seven agencies review distance education programs when at
least half of all courses in a program are offered through distance
learning. A fourth agency reviews at an earlier stage--when 25 percent
or more of a degree or certificate program are offered through distance
learning. The remaining three agencies have still other polices for
when they initiate reviews of distance education programs.
Education's Role and Responsibility in Monitoring Accrediting Agencies
Is Limited:
The variations among accrediting agencies that we found probably result
from the statutory latitude provided to accrediting agencies in
carrying out their roles. For example, in the use of their varying
policies and practices, the agencies are operating within the flexible
framework provided under the Higher Education Act. Such variations
likewise do not necessarily lead to differences in how effectively
agencies are able to evaluate educational quality. However, the lack of
consistently applied procedures for matters such as comparing distance
education and campus-based programs or deciding when to incorporate
reviews of new distance education programs could potentially increase
the chances that some schools are being held to higher standards than
others. Additionally, the flexible framework of the Higher Education
Act extends to the requirements that accrediting agencies set for
schools in evaluating student learning outcomes. In discussions on this
matter, Education officials indicated that the law's flexibility
largely precludes them from being more prescriptive about the
standards, policies, or procedures that accrediting agencies should
use.
Accrediting Agency Assessment of Student Learning Outcomes in Their
Reviews Varies Considerably:
The seven accrediting agencies we reviewed varied in the extent to
which their standards and policies address student-learning outcomes
for either campus-based or distance education courses or programs. Over
the past decade, our work on outcomes-based assessments in a variety of
different areas shows that when organizations successfully focus on
outcomes, they do so through a systematic approach that includes three
main components.[Footnote 29] The three are (1) setting measurable and
quantifiable goals for program outcomes, (2) developing strategies for
achieving these goals, and (3) disclosing the results of their efforts
to the public. The accrediting agencies we reviewed generally
recognized the importance of outcomes, but only one of the seven had an
approach that required schools to cover all three of these components.
Successful Implementation of Outcomes-Based Approach Generally
Involves Three Main Components:
The three-part approach we found being used to successfully implement
an outcomes-based management strategy was based on our assessments
across a wide spectrum of agencies and activities, including, for
example, the Federal Emergency Management Agency working with local
governments and the building industry to strengthen building codes to
limit deaths and property losses from disaster and the Coast Guard
working with the towing industry to reduce marine casualties. Briefly,
here are examples of how these three components would apply in an
educational setting.
Developing measurable and quantifiable goals. It is important that
outcome goals be measurable and quantifiable, because without such
specificity there is little opportunity to determine progress
objectively. A goal of improving student learning outcomes would
require measures that reflect the achievement of student learning. For
example, a goal of improving student learning outcomes would need to be
translated into more specific and measurable terms that pertain
directly to a school's mission, such as an average state licensing
examination score or a certain job placement rate. Other measures could
include test scores measuring writing ability, the ability to defend a
point orally, or analyze critically, and work habits, such as time
management and organization skills.
Developing strategies for achieving the goals. This component involves
determining how human, financial, and other resources will be applied
to achieve the goals. In education, this component could include such
strategies as training for faculty, investments in information
technology, or tutoring programs to help improve skills to desired
levels. This component helps align an organization's efforts towards
improving its efficiency and effectiveness. Our work has shown that
providing a rationale for how the resources will contribute to
accomplishing the expected level of performance is an important part of
this component.
Reporting performance data to the public. Making student learning
outcome results public is a primary means of demonstrating performance
and holding institutions accountable for results. Doing so could
involve such steps as requiring schools to put distance learning goals
and student outcomes (such as job placement rates or pass rates on
state licensing examinations) in a form that can be distributed
publicly, such as on the school's Web site. This would provide a basis
for students to make more informed decisions on whether to enroll in
distance education programs and courses. It would also provide feedback
to schools on where to focus their efforts to improve performance.
Education's 2002-2007 strategic plan calls for public disclosure of
data by stating, "[A]n effective strategy for ensuring that
institutions are held accountable for results is to make information on
student achievement and attainment available to the public, thus
enabling prospective students to make informed choices about where to
attend college and how to spend their tuition dollars."[Footnote 30]
Similarly, in September 2003, the Council for Higher Education
Accreditation stated that "institutions and programs should routinely
provide students and prospective students with information about
student learning outcomes and institutional and program performance in
terms of these outcomes" and that accrediting organizations should
"establish standards, policies and review processes that visibly and
clearly expect institutions and programs to discharge [such]
responsibilities."[Footnote 31]
Most Accrediting Agencies Lacked One or More Components:
The accrediting agencies we reviewed generally recognized the
importance of student learning outcomes and had practices in place that
embody some aspects of the outcomes-based approach. However, only one
of the agencies required schools to have all three components in place.
Developing measurable and quantifiable goals. Five of seven agencies
had standards or policies requiring that institutions develop
measurable goals.[Footnote 32] For example, one accrediting agency
required institutions to formulate goals for its distance learning
programs and campus-based programs that cover student achievement,
including course completion rates, state licensing examination scores,
and job placement rates. Another accrediting agency required that
schools set expectations for student learning in various ways. For
example, the agency required institutions to begin with measures
already in place, such as course and program completion rate, retention
rate, graduation rate, and job placement rate.
We recognize that each institution will need to develop its own
measures in a way that is aligned with its mission, the students it
serves, and its strategic plans. For example, a 2-year community
college that serves a high percentage of low-income students may have a
different mission, such as preparing students for 4-year schools, than
a major 4-year institution.
Developing strategies for achieving the goals. All of the agencies we
visited had standards or policies requiring institutions to develop
strategies for achieving goals and allocating resources. For example,
one agency had a standard that requires institutions to effectively
organize the human, financial, and physical resources necessary to
accomplish its purposes. Another agency had a standard that an
institution's student development services must have adequate human,
physical, financial, and equipment resources to support the goals of
the institution. In addition, the standard requires that staff
development to be related to the goals of the student development
program and should be designed to enhance staff competencies and
awareness of current theory and practice. Our prior work on
accountability systems, however, points out that when measurable goals
are not set, developing strategies may be less effective because there
is no way to measure the results of applying the strategies and no way
of determining what strategies to develop.
Our visits to the accrediting agencies produced specific examples of
schools they reviewed that had tangible results in developing
strategies for meeting distance education goals. One was Old Dominion
University, which had collected data on the writing skills of distance
education students. When scores by distance learners declined during an
academic year, school administrators identified several strategies to
improve students' writing abilities. They had site directors provide
information on tutoring to students and directed students to writing
and testing centers at community colleges. In addition, they conducted
writing workshops at sites where a demonstrated need existed. After
putting these strategies in place, writing test scores improved.
Reporting performance data to the public. Only one of the agencies had
standards or policies requiring institutions to disclose student
learning outcomes to the public. However, various organizations,
including the Council for Higher Education Accreditation, are
considering ways to make the results of such performance assessments
transparent and available to the public. Among other things, the
Council is working with institutions and programs to create individual
performance profiles or to expand existing profiles. The Student Right
to Know and Campus Security Act of 1990 offers some context for
reporting performance data to the public.[Footnote 33] This act
requires schools involved in the federal student loan programs to
disclose, among other things,[Footnote 34] completion or graduation
rates and, if applicable, transfer-out rates for certificate-or degree-
seeking, full-time, first-time undergraduates.[Footnote 35] In this
regard, Education is considering ways to make available on its Web site
the graduation rates of these schools. However, according to two
postsecondary experts, the extent that schools make such information
available to prospective students may be uneven.
Conclusions:
The federal government has a substantial interest in the quality of
postsecondary education, including distance education programs. As
distance education programs continue to grow in popularity, statutory
restrictions on the size of distance education programs--put in place
to guard against fraud and abuse in correspondence schools--might soon
result in increasing numbers of distance education students losing
eligibility for federal student aid. At the same time, some form of
control is needed to prevent the potential for fraud and abuse. Over
the past few years, the Department of Education has had the authority
to grant waivers to schools in the Demonstration Program so that
schools can bypass existing statutory requirements. The waivers offer
schools the flexibility to increase the size of their distance
education programs while remaining under the watchful eye of Education.
Education is required to evaluate the efficacy of these waivers as a
way of determining the ultimate need for changing the statutory
restrictions against distance education. To do so, the Department would
need to develop data on the cost to the federal student aid programs of
granting waivers to schools. Developing such data and evaluating the
efficacy of waivers would be a helpful step in providing information to
the Congress about ways for balancing the need to protect the federal
student aid programs against fraud and abuse while potentially
providing students with increased access to postsecondary education.
In addition to administering the federal student aid programs,
Education is responsible for ensuring the quality of distance education
through the postsecondary accreditation process. Among other things,
measures of the quality of postsecondary education include student-
learning outcomes, such as the extent to which students complete
programs and/or the extent to which students' performance improves over
time. As distance education programs proliferate, challenges with
evaluating these programs mount because accreditation procedures were
developed around campus-based, classroom learning. There is growing
awareness in the postsecondary education community that additional
steps may be needed to evaluate and ensure the quality of distance
education and campus-based programs, though there is far less unanimity
about how to go about it. Several accrediting agencies have taken
significant steps towards applying an outcome-based, results-oriented
approach to their accreditation process, including for distance
education. These steps represent a potential set of "best practices"
that could provide greater accountability for the quality of distance
education. Due to the autonomous nature of accrediting agency
operations, Education cannot require that all accrediting agencies
adopt these practices. It could, however, play a pivotal role in
encouraging and fostering the use of an outcomes-based model. In the
long run, if the practices of accrediting agencies remain so varied
that program quality is affected, Education may need additional
authority to bring about a more consistent approach. Finally, if
Education wishes to hold schools more accountable for the quality of
distance education and campus-based programs--such as ensuring that a
minimum percentage of students complete their programs--aligning the
efforts of accrediting agencies to ensure that these factors are
measured could increase the likelihood for success in this area.
Indeed, a more systematic approach by accrediting agencies could help
Education in its effort to focus greater attention on evaluating
schools and educational policy through such outcomes.
Recommendations:
To better inform federal policymakers, we recommend that the Secretary
of Education include data in future Demonstration Program reports on
the potential cost to the federal student aid programs of waiving the
50-percent rules. To enhance oversight of distance education quality,
we recommend that the Secretary of Education, (1) develop, with the
help of accrediting agencies and schools, guidelines or a mutual
understanding for more consistent and thorough assessment of distance
education programs, including developing evaluative components for
holding schools accountable for such outcomes and (2) if necessary,
request authority from the Congress to require that accrediting
agencies use these guidelines in their accreditation efforts.
Agency Comments:
In commenting on a draft of this report, Education generally agreed
with our findings and the merits of our recommendations. For instance,
Education said that it will consider the potential cost of the federal
student aid programs of eliminating the 50-percent rules; however, due
to the timing of the process of reauthorizing the Higher Education Act,
Education believes it is unlikely these estimates will become part of a
future report to Congress on the Demonstration Program. While we can
appreciate the difficulties surrounding the timing of the
reauthorization, we believe that policymakers would be better informed
if this information was provided to them as part of the Demonstration
Program. Given the uncertainty about whether Congress will indeed amend
the 50-percent rules as part of reauthorization and that the timing of
such changes is uncertain, providing information on the costs of the
waivers would appear to have value--especially since such information
would, in part, carry out the spirit of Demonstration Program
requirements.
With respect to our recommendation for accreditation, Education said
that it would study it carefully. Education agrees that it could engage
in a series of discussions with accrediting agencies and schools
leading to guidance on assessment and public disclosure of information.
Education, however, said that the results would be largely
informational because the agencies would not be required to adopt the
guidance, and Education is not convinced of the necessity or
appropriateness of requiring the guidance via the Higher Education Act.
Again, we can appreciate Education's position on this issue, but
continue to believe that greater accountability for student learning
outcomes is necessary for enhanced oversight of distance education
programs. Given Education's stated desire to hold institutions more
accountable for results, such as ensuring a higher percentage of
students complete their programs on time, working with accrediting
agencies to develop guidelines or a mutual understanding of what this
involves would be one management tool for doing so.
We are sending copies of this report to the Secretary of Education,
appropriate congressional committees, and other interested parties. In
addition, the report will be available at no charge on GAO's Web site
at http://www.gao.gov. Please call me at (202) 512-8403 if you or your
staffs have any questions about this report. Other contacts and
acknowledgments are listed in appendix III.
Signed by:
Cornelia M. Ashby:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
To address the two questions about the extent to which current federal
restrictions on distance education affect schools' ability to offer
federal student aid to their students and what the Department of
Education's Distance Education Demonstration Program has revealed with
respect to the continued appropriateness of these restrictions, we
obtained information from Education staff and other experts on which
postsecondary institutions might be affected by these provisions or
were close to being affected. We limited our work primarily to schools
that were involved in the Demonstration Program or had electronically
transmitted distance education programs and that were accredited or
pre-accredited by accrediting agencies recognized by Education for
eligibility in the federal student aid programs. We initially
interviewed officials at 21 institutions with a standard set of
questions regarding the effect, if any, current federal restrictions
have on the schools' ability to offer federal student aid, and we
obtained information on the distance education programs at the schools.
Based on our interviews, we determined that only 14 of the 21 schools
had been affected or could be affected by the restrictions. We also
obtained data on default rates at the 14 schools, if applicable, from
Education's student loan cohort default rate database. With respect to
the Demonstration Program, we interviewed officials at Education who
were responsible for assessing distance education issues. Additionally,
we reviewed monitoring and progress reports on participating
institutions involved in the Demonstration Program. We reviewed various
reports on federal restrictions related to distance education as well
as pertinent statutes and regulations.
To address the two questions related to the work of accrediting
agencies: To what extent do accreditation agencies include distance
education in their reviews of schools or programs and as they evaluate
distance education programs and campus-based programs, to what extent
do accreditation agencies assess educational outcomes, we focused on
the standards and policies of seven accrediting agencies that
collectively are responsible for more than two-thirds of all distance
education programs.[Footnote 36] We interviewed agency administrators
and evaluated the extent of their outcomes-based assessment standards
and policies using criteria that we had developed in a variety of past
work addressing performance and accountability issues. We compared
accrediting agency standards and policies with prior work we conducted
on key components for accountability. We provided our preliminary
findings to the seven accrediting agencies and asked them to verify our
initial findings. In addition, we interviewed staff at Education
involved in accreditation issues. We reviewed Education's monitoring
reports on accreditation agencies. Additionally, we interviewed
officials at the Council for Higher Education Accreditation and
reviewed various reports that they have produced.
We conducted our work in accordance with generally accepted government
auditing standards from October 2002 to February 2004.
[End of section]
Appendix II: Comments from the Department of Education:
UNITED STATES DEPARTMENT OF EDUCATION:
OFFICE OF POSTSECONDARY EDUCATION:
FEB 20 2004:
THE ASSISTANT SECRETARY:
Ms. Cornelia M. Ashby
Director, Education, Workforce, and Income Security Issues
United States General Accounting Office
Washington, DC 20548:
Dear Ms. Ashby:
Thank you for providing the Department of Education (the Department)
with a draft copy of the U.S. General Accounting Office's (GAO's)
report entitled, "Distance Education: Improved Data on Program Costs
and Guidelines on Quality Assessments Needed to Inform Federal Policy"
(GAO-04-279). We have reviewed the draft and have the following
comments.
This study focuses on the appropriateness of the limitations on the
size of distance education programs currently in place for institutions
to participate in the Title IV programs, as well as whether data exist
that may be utilized to support easing those restrictions.
Additionally, this report raises the issues of cost to the federal
student aid programs if certain restrictions are waived. A third focus
of the report is the review of seven accrediting agencies and their
approaches to examining distance programs, particularly whether they
have included assessments of student outcomes as part of that review.
In this report, you recommend that the Department:
* include empirical data in future Demonstration Program reports on the
potential cost to the federal student aid programs of waiving the 50
percent rules;
* enhance oversight of distance education quality by developing, with
the help of accrediting agencies and schools, guidelines or a mutual
understanding for more consistent and thorough assessment and public
disclosure of distance education programs, including developing
evaluative components for holding schools accountable for such
outcomes; and:
* if necessary, request authority from the Congress to require that
accrediting agencies use these guidelines in their accreditation
efforts.
In the President's fiscal year 2005 budget, we propose to make higher
education more accessible by expanding college and university options
for offering courses and programs online. As we work with Congress to
develop specific legislative proposals, we will look carefully at the
issues associated with the rules that limit the participation of
institutions that offer more than 50 percent of courses or enroll more
than 50 percent of their students via distance learning. As we work
with Congress, we will carefully consider the potential cost to the
federal student aid programs of eliminating the 50 percent rules.
However, because of the timing of the process of reauthorizing the
Higher Education Act of 1965, as amended (HEA), it is unlikely that
these estimates will become part of a future report to Congress on
the Demonstration Program.
We will also look carefully at your recommendations for accreditation
in the area of distance learning. While the Department could engage in
a series of discussions with accrediting agencies and schools leading
to "guidance" in the form of information about best practices in
accrediting distance education programs, this "guidance" would be
primarily informational. Statutory flexibility for accrediting
agencies, as GAO acknowledges, provides them with the discretion to
decide whether they would adopt or implement any or all of the
recommended practices. It is not clear, at this point, whether it would
be necessary or appropriate to make changes to the HEA to require that
accrediting agencies use certain guidelines in their accreditation
efforts.
I appreciate your examination of this important issue. We have provided
to your staff some technical comments on the report. The Department is
committed to the continued development of distance education.
Sincerely,
Signed by:
Sally L. Stroup:
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
Contacts:
Kelsey Bright, Assistant Director (202) 512-9037 Neil Asaba, Analyst-
in-Charge (206) 287-4774:
Staff Acknowledgments:
In addition to those named above, Jerry Aiken, Jessica Botsford,
Elizabeth Curda, Luann Moy, Corinna Nicolaou, Jill Peterson, Stan
Stenersen, and Susan Zimmerman made important contributions to this
report.
FOOTNOTES
[1] 34 CFR 600.2 states that a correspondence course is (1) a home
study course provided by an institution under which the institution
provides instructional materials, including examinations on the
materials, to students who are not physically attending classes at the
institution. When students complete a portion of the instructional
materials, the students take the examinations that relate to that
portion of the materials and return the examinations to the institution
for grading; (2) a home study course that provides instruction in whole
or in part through the use of video cassettes or video discs in an
award year is a correspondence course unless the institution also
delivers the instruction on the cassette or disc to students physically
attending classes at the institution during the same award year, and
(3) a course at an institution that may otherwise satisfy the
definition of a "telecommunications course" is a correspondence course
if the sum of telecommunications and other correspondence courses
offered by that institution equals or exceeds 50 percent of the total
courses offered at that institution. In addition, if a course is part
correspondence and part residential training, the course is considered
to be a correspondence course.
[2] 34 CFR 600.2 states that a telecommunications course is a course
offered principally through the use of television, audio, or computer
transmission, including open broadcast, closed circuit, cable,
microwave, satellite, audio conferencing, computer conferencing, video
cassettes, or discs. The term "telecommunications" does not include a
course that is delivered using video cassettes or disc recordings
unless the institution also delivers comparable instruction offered on
the cassettes or discs to students physically attending classes at the
institution during the same award year. If the course offered in the
manner described above does not qualify as a telecommunications course,
it is considered to be a correspondence course.
[3] The estimated number of students taking at least one
telecommunications distance education course is derived from our
analysis of the National Postsecondary Student Aid Study database. The
database did not include information on correspondence students.
[4] The 50-percent rules involve three main statutory restrictions.
First, under 20 U.S.C. 1002(a)(3)(A), a school that would otherwise be
eligible for the federal student aid programs becomes ineligible if
more than 50 percent of its courses are offered by correspondence.
Second, under 20 U.S.C. 1002(a)(3)(B), an otherwise eligible school
becomes ineligible if 50 percent or more of its students are enrolled
in correspondence courses. Third, under 20 U.S.C. 1091(l)(1)(A), a
student enrolled in a course of instruction that is offered in whole or
in part through telecommunications and leads to a certificate for a
program of 1 year or longer, or a recognized associate, baccalaureate,
or graduate degree conferred by such institution, shall not be
considered to be enrolled in correspondence courses unless the total
amount of telecommunications and correspondence courses at such
institution equals or exceeds 50 percent of the total number of courses
at the institution.
[5] In authorizing the Demonstration Program, the Congress also called
on Education to report annually on federal laws and regulations that
could impact access to distance education.
[6] Education defines an accrediting agency as a legal entity, or that
part of a legal entity, that conducts accrediting activities through
voluntary, nonfederal peer review and makes decisions concerning the
accreditation or preaccreditation status of institutions, programs, or
both.
[7] See U.S. General Accounting Office, Distance Education: Growth in
Distance Education Programs and Implications for Federal Education
Policy, GAO-02-1125T (Washington, D.C.: Sept. 26, 2002); Distance
Education: More Data Could Improve Education's Ability to Track
Technology at Minority Serving Institutions, GAO-03-900 (Washington,
D.C.: Sept. 12, 2003); and Distance Education: Challenges for Minority
Serving Institutions and Implications for Federal Education Policy,
GAO-04-78T (Washington D.C.: Oct. 6, 2003).
[8] We excluded correspondence schools from our review because
telecommunications distance education has been the main force behind
the recent growth in distance education programs.
[9] See U.S. Department of Education, Report to Congress on the
Distance Education Demonstration Program, (Washington, D.C.: January
2001) and Distance Education Demonstration Program - Second Report to
Congress, Department of Education (Washington, D.C.: July 2003).
[10] The seven agencies are (1) Middle States Association of Colleges
and Schools, (2) Western Association of Schools and Colleges -
Accrediting Commission for Community and Junior Colleges, (3) New
England Association of Schools and Colleges, (4) North Central
Association of Colleges and Schools, (5) Northwest Association of
Schools and Colleges, (6) Southern Association of Colleges and Schools,
and (7) the Accrediting Council for Independent Colleges and Schools.
[11] See U.S. General Accounting Office, Executive Guide: Effectively
Implementing the Government Performance and Results Act, GAO/GGD-96-118
(Washington, D.C.: June 1996).
[12] See GAO-02-1125T. Our analysis also showed that distance education
students tended to have higher income levels, a fact that may help
explain why fewer of them rely on federal assistance.
[13] In general, there are two main types of accrediting agencies--
regional and national. Regional accrediting agencies review
institutions in a region of the United States that includes at least
three states that are reasonably close to one another. National
accrediting agencies review programs or specialized institutions, such
as acupuncture schools or private business schools, on a national
basis.
[14] 20 U.S.C. 1099b(a)(5).
[15] 20 U.S.C. 1099b(a)(4).
[16] See U.S. Department of Education, Fiscal Year 2004 Annual Plan
(Washington, D.C.: March 2003).
[17] See Business-Higher Education Forum, Building a Nation of
Learners: The Need for Changes in Teaching and Learning to Meet Global
Challenges (Washington, D.C.: June 2003).
[18] See Council for Higher Education Accreditation, Statement of
Mutual Responsibilities for Student Learning Outcomes: Accreditation,
Institutions, and Programs (Washington, D.C.: September 2003). Also, in
May 2003, the Council identified six areas for accreditation and
accountability reform, including expanding the use of student learning
outcomes in accreditation reviews, offering more information to the
public on the findings of accreditation reviews, and reviewing any
distance learning providers or offerings that may become eligible for
the federal student aid programs.
[19] See U.S. General Accounting Office, College Completion: Additional
Efforts Could Help Education with Its Completion Goals, GAO-03-568
(Washington, D.C.: May 23, 2003).
[20] The Congress established the Web-based Education Commission to
prepare a report to the President and the Congress that contains
recommendations for legislation and administrative actions, including
those pertaining to the appropriate federal role in determining the
quality of educational software products. Members of the Commission
included Senators, Representatives, and leaders from postsecondary
institutions.
[21] See Web-based Education Commission, The Power of the Internet for
Learning: Moving from Promise to Practice, (Washington, D.C.: December
2000).
[22] Participation in the Demonstration Program does not necessarily
exempt schools from federal restrictions on the size of their distance
education programs. Schools must apply for waivers and Education
reviews the applications and determines whether to grant the waivers.
Through November 2003, there were 21 participants in the Demonstration
Program. In December 2003, Education expanded the program to 26
participants.
[23] In commenting on a draft of this report, an Education official
indicated that Graceland University, a private nonprofit school,
located in Limoni, Iowa was also affected by the 50 percent rules. The
school serves over 3,000 students and is a new participant in the
Demonstration Program. Education plans to grant the school waivers to
the 50 percent rules.
[24] In January 2003, H.R. 12--Fed Up Higher Education Technical
Amendments Act of 2003 and in April 2003, S. 901--Higher Education
Technical Amendments Act of 2003, proposed that telecommunication
courses would not be considered correspondence courses for purposes of
the 50-percent rules if a school had a default rate of 10 percent or
less for each of the 3 most recent fiscal years.
[25] Our analysis of the three options is based on several data
sources, including Education's monitoring reports on schools
participating in the Demonstration Program, structured interviews with
officials at schools that are affected or that could be affected by
federal restrictions, interviews with Education officials, a student
loan cohort default rate data base and prior reports on the federal
financial aid programs. Regarding the accuracy of the student loan
cohort default rate database, Education sends preliminary default rate
data to each school to verify the accuracy of the data.
[26] The "Best Practices for Electronically Offered Degree and
Certificate Programs" was drafted by the Western Cooperative for
Educational Telecommunications in Colorado. The executive directors of
the eight regional accrediting agencies (including six covered in our
review) requested the study on best practices to assist institutions in
planning distance education activities and to provide a self-assessment
framework for those already involved. According to the "best
practices," overall program effectiveness is determined by such
measures as student retention rates and student competence in
fundamental skills such as communication, comprehension, and analysis.
[27] Four of six regional accrediting agencies we reviewed also had
additional standards or policies that applied to schools with distance
education programs.
[28] 34 C.F.R. 602.22(a)(2)(i) thru (vii).
[29] See GAO/GGD-96-118.
[30] U.S. Department of Education, Strategic Plan 2002-2007.
[31] See Council for Higher Education Accreditation, Statement of
Mutual Responsibilities for Student Learning Outcomes: Accreditation,
Institutions, and Programs (Washington, D.C.: September 2003).
[32] Two agencies did not require institutions to set measurable goals.
Instead, they required schools to set goals without requiring them to
be measurable.
[33] Pub. L. No. 101-542, Nov. 8, 1990.
[34] The act also requires schools to report information on graduation
rates of students who receive athletically related student aid and
crimes committed on and off campus.
[35] Education plans to release graduation rate data on all schools
involved in the federal student aid programs in 2004.
[36] The seven are Middle States Association of Colleges and Schools,
Western Association of Schools and Colleges--Accrediting Commission for
Community and Junior Colleges, the New England Association of Schools
and Colleges, North Central Association of Colleges and Schools,
Northwest Association of Schools and Colleges, Southern Association of
Colleges and Schools, and the Accrediting Council for Independent
Colleges and Schools.
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